The requirement, in our words
Clause 8(1)(c) names four groups as officials: the National Armaments Director; APS employees who assist the Director; ADF members assigned to the Director; and people from other Commonwealth entities or Commonwealth companies assigned to the Director. The explanatory statement says Act sections 25 to 29 apply to these officials and that the Director may delegate powers to them under section 110.
What the provision is doing
The list decides who is inside the finance law. Official status is what attaches the duties of care and diligence, honesty and good faith, proper use of position, proper use of information and disclosure of interests. It also decides who can receive a delegation and who must be covered by the accountable authority instructions, the interests register and the training programme.
What good practice looks like
Build the register with the four classes and one row per person. Check the establishment order before day one: the DDA is an Executive Agency under the Public Service Act 1999, and the Agency Head may be a different person from the National Armaments Director. If they are different, record both roles and the instruction chain.
What changed
Before commencement the listed persons are not officials of the DDA, because there is no DDA for the finance law. After commencement, a person in one of the four classes is an official even if they are employed by another entity or are a member of the ADF. That is the part most easily missed: an APS employee in Defence who is assigned to work for the National Armaments Director, and an official of another Commonwealth entity on secondment, can both be officials of the DDA for the finance law while remaining in their home organisation for other purposes.
Evidence an auditor or portfolio reviewer asks for
| Category | Record to keep | Retention |
|---|---|---|
| Officials register | A register with one row per official, the class in clause 8(1)(c), the engagement or making-available basis, the start and end dates and the evidence for the arrangement. | Seven years after the arrangement ends. |
| Making-available records | Secondment agreements, ADF service arrangements and letters for officials of other entities, each identifying the DDA as the entity to which the person is made available. | Seven years after the arrangement ends. |
| Duties briefing | Records showing each official was briefed on Act sections 25 to 29, the interests disclosure process and the accountable authority instructions. | Seven years. |
| Interests register | The register of material personal interests and the disclosure forms, with the process for the National Armaments Director and for other officials kept distinct. | Seven years after the interest ends. |
| Public interest disclosure | The principal officer's written procedures, the authorised officer list and the training record for the disclosure scheme. | Current, plus seven years of records. |
Common gaps
- Only APS employees are on the register; ADF members and officials of other entities are left off.
- The secondment letter does not identify the Director as the person the secondee works for.
- The interests process is copied from Defence without separating the accountable authority from other officials.
- The public interest disclosure principal officer is not identified before day one.
What to do before 1 July 2027
- Build the register with the four classes and one row per person.
- Collect the making-available evidence for every person outside the DDA's own APS cohort.
- Brief every official on sections 25 to 29 and the disclosure process.
- Issue the public interest disclosure procedures and name the authorised officers.
Dates and cross-references
Commences: 1 July 2027, stated in section 2 of F2026L01074. Retention: Not stated in the text.
Read with: accountable-authority, defence-capability-and-minister.
Source
This page reads Public Governance, Performance and Accountability Amendment (Defence Delivery Agency) Rules 2026 (F2026L01074) and its explanatory statement, against the PGPA Act 2013 and the PGPA Rule 2014 Compilation No. 64. Retrieved 2026-10-20. The requirement above is our own statement, not the instrument wording. Not legal advice; does not certify.